My CEO just returned from a conference and asked me whether we do a monthly screen on people that are issued credit cards. My response was that if they have other accounts we do, but if they are not a customer of the bank, then no. We issue Visa credit cards embossed with our bank name, but not all of these people have bank accounts, so they are not customers of the bank. My CEO said that the S & S examiners are going to be asking that we do this check. Thoughts?

We're not in the credit card business, so I'm probably missing something, but if you are issuing them a credit card, how are they not customers of your bank?

I agree with Lee S - we issue Visa cards and scrub all applicants. They are treated like any other customer.